Canada-U.S. Blog Trade Lawyers Cyndee Todgham Cherniak and Susan K. Ross

Canada Publishes A Consolidated SEMA Sanctions List

Posted in Canada's Federal Government, Export Controls & Economic Sanctions, Exports

On October 12, 2017, Global Affairs Canada published a Consolidated Special Economic Measures Act Sanctions List.  Before today, Canadian companies had to review each regulation promulgated under the Special Economic Measures Act when conducting due diligence.  However, and this is important, the Global Affairs Consolidated Special Economic Measures Act Sanctions List does not include sanctions under the United Nations Act.  As  result, it is still necessary to review each regulation promulgated under the United Nations Act.

The Consolidated SEMA Sanctions List was last updated on October 7th.  The Venezuela SEMA sanctions are included.  However, if the Consolidated SEMA Sanctions List is not updated when new SEMA sanctions are imposed, the list will not be useful for very long.

The Consolidated SEMA List has been requested by Canada’s economic sanctions lawyers for years (but we asked for all economic sanctions lists to be consolidated into a user-friendly list).  In April 2017, the House of Commons Standing Committee on Foreign Affairs and International Development (FAAE) issued a report entitled “A Coherent and Effective Approach: Canada’s Economic Sanctions Regimes: Sergei Magnitsky and Beyond” in which it recommended the following:

“The Government of Canada should produce and maintain a comprehensive, public and easily accessible list of all individuals and entities targeted by Canadian sanctions containing all information necessary to assist with the proper identification of those listed.”
On July 17, 2017, the Minister of Foreign Affairs responded in a letter and indicated that the recommendation would be implemented with respect to the SEMA sanctions.  Today’s list is what was promised.
For more information about Canada’s economic sanctions laws or to arrange for a diagnostic of your compliance program, please contact Cyndee Todgham Cherniak at 416-307-4168 or at Cyndee@LexSage.com. If you would like assistance in managing the process, Heather Innes, formerly in-house counsel at a company with export controls processes, would be happy to assist. Please call Heather at 416-350-1234.